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Amended WS Qaseem
Amended WS Qaseem
Versus
Muhammad Qaseem Paracha ………. Defendant
WRITTEN STATEMENT
PRELIMINARY OBJECTIONS:
That the above suit is liable to be dismissed on all or any of the following
A. That the plaintiff has no cause of action to institute and maintain the
instant suit.
B. That the prayers made in the above suit are barred by law.
C. That this court have no jurisdiction over to decide the above mentioned
suit as the Plaintiff is not residing at the above mentioned address and
concealed this fact with this Hon’ble Court, even that the address of the
D. That the suit being frivolous, baseless, vexatious and filed with malafide
from further harassment and to save the precious time of this Hon'ble
Court.
E. That the plaintiff has not come with clean hands before this Hon’ble Court
and the allegations contained in the plaint are baseless and malicious
F. That the above suit is based on absolutely incorrect, false and baseless
follows: -
suit, the above suit being still born is liable to be buried at the initial stage to
save the precious time of this Hon’ble Court and to save the defendant from
case of plaintiff and therefore, the instant suit is liable to be dismissed with
special cost.
Without prejudice to the above while reserving all rights to file all such
additional documents the para – wise reply of the plaint is as under:-
4. That the contents of paragraph no. 2 of the plaint are partially admitted to
the dower amount of Rs. 100,000/- It is submitted that the dower amount
(mother of the plaintiff) Zoya Khalid (Sister in law of the plaintiff) Khalid
Defendant) & other family members. Further submitted that the defendant
after consummation has demanded the dower amount from the plaintiff
which has been paid in a dinner arranged by the defendant for the family
members in whole.
5. That the contents of Para No. 3 and 4 of the plaint are incorrect, false,
baseless, misleading and malicious hence the same are denied. The plaintiff
is put to strict proof thereof. It is submitted that after marriage/ rukhsati the
Defendant showed himself as good, loyal and faithful husband the plaintiff
and his family members after some time quarrel with defendant with petty
issues. That it is further submitted that from the very beginning of the
marriage the husband and wife was living a very happy life and during the
witnessed on part of defendant but as the time laps, the behavior and attitude
of the parents and siblings of the plaintiff and the plaintiff herself changed
their behavior towards defendant and his family members, which is never
good as acceptable towards the defendant but as a god fearing person and to
save the relationship the defendant has Bourne their improper and
7. That the contents of Para No. 6 to 8 of the plaint are incorrect, false,
baseless, misleading and malicious hence the same are denied. The plaintiff
dinner table having dinner and the plaintiff also having the dinner and
politely told her that she refused due to pregnancy which needs much
caution and care and it’s too late to go to her house, during that the plaintiff
left her mobile phone on the dinner table and go to request again to her
constant messages from Zoya Khalid (sister in law of plaintiff) checked her
phone and shocked to read very abusive language without any valid cause
on which the defendant taken screen shots of the chats to show this to his
family and immediately ask his father to call plaintiff father, on showing
such messages the defendant made a call to plaintiff father and asked to
come to his immediately, after around 3 hours the brother and father of the
Plaintiff misbehaved with the Defendant and his father and said that they
will meet the Defendant in the Court. However, the Defendant kept on
trying for the reconciliation but their family influenced the defendant to
break the marriage and thus detained the plaintiff to her parents’ house.
(Copy of What’s App Chat’s are attached and marked as Annex “A/1”,
admitted to the extent of the minor was born in June 2022 for which all the
it is submitted that the receipts attached with the amended plaint also
9. That the contents of paragraph no. 6-B of the application of the plaintiff are
incorrect, false, baseless, misleading and malicious hence the same are
denied. The plaintiff is put to strict proof thereof. It is submitted that the
school and the annexures provided P/9 and P/10 are just details of admission
10. That the contents of paragraph no. 6-C of the application are partially
admitted to the extent of Divorce against the dower amount of Rs. 100,000/-
It is submitted that the dower amount has been paid in shape of cash to
submitted that the defendant after consummation has demanded the dower
amount from the plaintiff which has been paid in a dinner arranged by the
Defendant in the tough times of inflation cannot afford Rs. 15000/- as Iddat
Plaintiff No. 2.
11. That the contents of paragraph no. 6-D of the application is partially
sum of Rs. 38,800.0 as net pay in hand and who is the only person who
earns bread and butter for his family. It is pertinent to mention here that the
father of the defendant is a retired person from the same Govt. Office on
19.05.2021 and mother of the defendant is also old infirm lady who needs
12. That the contents of paragraph no. 6-E of the application is incorrect, false,
baseless, misleading and malicious hence the same are denied. The plaintiff
called the Defendant and offer to meet the Babies and asked to returned the
CNIC which is already delivered to the Plaintiff Mother on the said date.
13. That the contents of paragraph no. 9 of the plaint are partially admitted to
incorrect and false and baseless. It is submitted that the defendant is having
a sum of Rs. 38,686.0 as net pay in hand and who is the only person who
earns bread and butter for his family. It is pertinent to mention here that the
father of the defendant is a retired person from the same Govt. Office on
19.05.2021 and mother of the defendant is also old infirm lady who needs
14. That the contents of Para No. 10 to 11 of the plaint are incorrect, false,
baseless, misleading and malicious hence the same are denied. The plaintiff
is put to strict proof thereof. That when the Defendant came to know about
it he tried very hard to save the marriage and in this regard he contacted
Divorce Deed to the Plaintiff at her residence (which was duly received)
after all his efforts went in vain. That it is submitted that the defendant is
“C”)
15. That the contents of plaint are vehemently denied and the plaintiff is put to
strict proof thereof. It is specifically denied that any cause of action has
accrued for filing the above suit hence, the suit being without cause of
16. That the contents of prayer of the plaint are incorrect and are denied. It is
specifically denied that the plaintiff is entitled to any or all of the relieves as
claimed. It is submitted that the plaint contain false, baseless, fabricated and
PRAYER
conscience that this Hon’ble Court may be pleased to dismiss the above suit with
compensatory cost.
DEFENDANT
VERIFICATION
Karachi; DEPONENT
Dated:
ADVOCATE
VERSUS
M. Qaseem Paracha…………………………………………………Defendant
1. That I am the Defendant in the above mentioned suit well conversant with
2. That the Plaintiff(s) filed a suit on 05.03.2022, after which the Defendant
Family Act the Hon’ble Court pleased to Order the Interim Maintenance
Maintenance regularly.
3. That the Plaintiff No. 3, Muhammad Muzamil (Son) was born in June
net pay in hand and who is the only person who earns bread and butter for
his family. It is pertinent to mention here that the father of the defendant is
a retired person from the same Govt. Office on 19.05.2021 and mother of
the defendant is also old infirm lady who needs constant medical
assistance which is also barred by the defendant as such cannot afford Rs.
12000/- per month as such respectfully prayed to recall the Order dt.
10.05.2022 and fix the interim maintenance as Rs. 3000/- each child.
dismiss the under reply application Under Section 17-A and may be
passed order to fix the interim maintenance for each child as Rs. 3000/-
per month.
VERSUS
M. Qaseem Paracha…………………………………………………Defendant
AFFIDAVIT:
adult, R/o House No. R-1183, Block-16, FB Area, Karachi do hereby state on
oath as under:-
1. That I say that I am Defendant in above suit, as such well conversant with
2. That I say that I have gone through the application U/s 17-A of Family
Court Act 1964, as amended upto date filed by the Plaintiff, as such
3. That I say that it is submitted that the under reply application is frivolous,
Dated: